On 7 October 2026, the Støre government presented its proposal for the 2027 state budget. Below are the most important, proposed changes in international tax.
The major international tax change in the 2027 state budget concerns the Top-up Tax Act. The Act implements an international model framework to ensure global minimum taxation (Pillar 2). The framework is intended to ensure that large groups are taxed at a minimum of 15%, regardless of where they conduct their business.
The budget proposal introduces four new Safe Harbour rules. The Safe Harbour rules are an arrangement that allows groups to set the top-up tax to zero for entities in certain jurisdictions, without having to carry out the full and complex calculation of the effective tax rate, in cases where the risk of under-taxation is considered low.
The Simplified Effective Tax Rate Safe Harbour allows the group to demonstrate, through a simplified calculation based, among other things, on aggregated figures from the group's consolidated accounts, that the business in a jurisdiction has a low risk of under-taxation. If the calculation shows an effective tax rate of at least 15%, the top-up tax is set to zero.
Today, the Safe Harbour rules are regulated only by regulation, with a single general regulatory authority in section 5-7 of the Top-up Tax Act. The Ministry of Finance proposes to consolidate all the Safe Harbour rules, both those already in force and the four new ones, into a new separate chapter of the Act, with a dedicated regulatory authority for each rule.
As a result, the current regulatory authority is repealed, with effect from 4 January 2027.
The Government proposes to extend the share savings account scheme to also cover shares and equity certificates admitted to trading on a multilateral trading facility (MTF), and not only ordinary regulated markets such as a stock exchange. This also opens up the possibility of placing foreign, non-listed shares traded on such marketplaces in a share savings account.
The extension raises separate questions regarding tax reporting of foreign shares, since the Norwegian Tax Administration does not have underlying data on the wealth values of companies that do not file tax returns in Norway. The Ministry's solution is that the provider of the share savings account must itself report the wealth value of foreign, non-listed shares, based on the assumed sale value, by the deadline of 10 February in the tax assessment year.
The Ministry also proposes that the last known price shall be used as the basis when such securities are transferred between a person's own share savings accounts, or are deposited into or withdrawn from the account, including for securities with low or no trading activity over time. No transitional rule is introduced that would allow taxpayers to transfer existing securities into the extended share savings account without triggering capital gains taxation, partly because the Norwegian Tax Administration does not have historical data for MTF-traded shares that is as good as that for listed shares.
It is proposed that the changes to the share savings account scheme enter into force immediately, with effect from and including the 2027 income year.
Please note that the state budget must be adopted by Parliament, and the Government depends on support from other parties to secure adoption of the budget and the accompanying legislative proposals. We will continue to follow developments in the top-up tax rules and international tax cooperation going forward.